Justia Wyoming Supreme Court Opinion Summaries

The case centered around Appellant’s claim that he was the actual and presumptive father of a ten-year-old child. The district court granted the Mother’s petition to establish that Appellant was not the child’s father. The Supreme Court affirmed, holding that the district court did not err in (1) granting Mother’s petition to prove that Appellant was not the child’s biological father under the Wyoming Parentage Act; and (2) not finding that Appellant was a de facto parent or a parent by estoppel because the Court declined to adopt de facto parentage or parentage by estoppel, leaving instead that policy decision to the Wyoming Legislature. View "LP v. LF" on Justia Law

In October 2010, Appellant slipped and fell down a flight of stairs outside of her workplace. In January 2011, Appellant was diagnosed with avascular necrosis (AVN) in the femoral head of her right hip. Eventually, the femoral head on her right hip collapsed due to the AVN progression, and in December 2011 Appellant received a total right hip replacement. The Wyoming Department of Workforce Services, Workers’ Safety and Compensation Division denied Appellant’s claim for medical treatment of the AVN, concluding that Appellant’s October 2010 fall did not cause her to then develop AVN. After a contested case hearing, the Office of Administrative Hearings (OAH) agreed and denied benefits. The Supreme Court affirmed, holding that the OAH’s findings of fact and conclusions of law were supported by substantial evidence and were in accordance with the law. View "In re Worker's Compensation Claim of Stevens" on Justia Law

In 2011, after a jury trial, Defendant was convicted of aggravated burglary and kidnapping and found to be a habitual criminal. The district court sentenced Defendant to two concurrent life sentences. The Supreme Court affirmed the convictions and sentences. In 2013, Defendant filed a motion to correct an illegal sentence, arguing that one of the convictions the district court relied upon for the habitual criminal determination and the life sentences occurred when he was only sixteen years old and that consideration of that offense to impose a life sentence was unconstitutional under Miller v. Alabama. The district court denied Defendant’s motion to correct an illegal sentence. The Supreme Court affirmed, holding that the sentencing scheme at issue here did not mandate a life sentence for a juvenile, and therefore, Miller did not apply. View "Counts v. State" on Justia Law

Appellant, a juvenile, was convicted and sentenced. The Supreme Court reversed Appellant’s sentence, instructing that, if a sentence of life according to law was imposed, the district court must specify a period of parole ineligibility. The district court did as instructed and imposed a sentence of life according to law with the specification that Appellant was eligible for parole on the sentence after thirty-five years. The Supreme Court vacated the sentence imposed by the district court, holding that Appellant should be resentenced because the district court did not consider the analysis from Miller v. Alabama “in light of the entire sentencing package.” View "Sen v. State" on Justia Law

Sister filed a negligence action against Brother for injuries she sustained in a single-vehicle accident that occurred in Montana. Brother moved for summary judgment, contending that because the accident occurred in Montana, Wyoming’s borrowing statute required application of Montana’s three-year statute of limitations, and therefore, Sister’s action was barred. The Supreme Court affirmed, holding that the district court did not err in (1) rejecting application of Montana’s choice-of-law statutes in applying Wyoming’s borrowing statute; (2) determining that Sister’s cause of action arose in Montana; and (3) applying Montana’s three-year statute of limitations to bar Sister’s cause of action. View "Boutelle v. Boutelle" on Justia Law

Twelve-year-old J.K. underwent an appendectomy performed by Appellee, but complications arose requiring additional surgery and medical treatment. Appellants, on behalf of J.K., filed a medical malpractice claim against Appellee. Appellee moved to dismiss, alleging that the claim was barred by the two-year statute of limitations contained in Wyo. Stat. Ann. 1-3-107(a)(ii). The district court granted the motion. Appellants appealed, arguing that the statute, as applied to minors, violates the Wyoming Constitution. The Supreme Court agreed and therefore reversed, holding that section 1-3-107(a)(ii) violates the open courts provision of Wyoming’s Constitution by restricting a minor’s access to the courts. Remanded. View "Kordus v. Montes" on Justia Law

Jeffrey Irene was injured after being struck by a vehicle driven by Douglas Downs. Downs had been arrested for driving while under the influence of alcohol two hours before the incident, but Eric Overlie, a licensed bail bondsman and an agent of Lederman bonding company, posted bail to procure Downs’ release from custody. Seneca Insurance Company guaranteed the bond. Irene and the conservator of Irene’s minor children filed a negligence action against Overlie, Lederman, and Seneca. The district court granted Defendants’ motions to dismiss, concluding that the suit had not been filed within the two-year statute of limitations that governs causes of action arising from the rendering of licensed or professional services. The Supreme Court reversed, holding that the facts in the complaint did not establish that Overlie was rendering licensed or professional services when he released Downs from his custody. View "DeLauter v. Seneca Ins. Co., Inc." on Justia Law

The State filed a petition to terminate Mother’s parental rights to her two children pursuant to Wyo. Stat. Ann. 14-2-309(a)(iii) and 14-2-309(a)(v). After a trial, the district court determined that the State had proven by clear and convincing evidence that Mother’s parental rights should be terminated pursuant to both statutory provisions. Mother appealed. The Supreme Court affirmed, holding (1) the district court was not deprived of its jurisdiction when statutory deadlines were bypassed; (2) the evidence clearly and convincingly supported the district court’s decision to terminate Mother’s parental rights pursuant to section 14-2-309(a)(v); and (3) Mother waived her contention that she received ineffective assistance of counsel, and Mother’s argument that the cumulative effect of errors violated her due process rights failed. View "SAS v. State" on Justia Law

Western Ecosystems Technology, Inc. (Western) and GreenHunter Wind Energy, LLC entered into a contract whereby Western provided the LLC consulting services. When the LLC paid nothing for Western’s services, Western brought a breach of contract action against the LLC. Western obtained a judgment against the LLC. Because the LLC had no assets upon which Western could execute, Western brought this action against GreenHunter Energy, Inc. (Appellant), the sole member of the LLC, seeking to pierce the LLC’s veil and hold Appellant liable for the LLC’s contractual obligations. The district court found in favor of Western, pierced the LLC’s veil, and awarded a judgment of $45,807 against Appellant. The Supreme Court affirmed the district court’s judgment piercing the LLC’s veil and imposing liability on Appellant for its debt to Western, holding that the district court correctly applied the applicable law and that its findings of fact were not clearly erroneous. View "Greenhunter Energy, Inc. v. W. Ecosystems Tech., Inc." on Justia Law

Disagreements as to the operation of a family ranch led to this partition action. The district court found that the parties were entitled to partition and ordered the construction of a new ditch to carry the water Appellant received to her parcel of land. The Supreme Court reversed, holding that the district court’s order was not sufficiently complete to establish that a partition in kind could be made without manifest injury to the value of the property and that the division was equitable to all parties. Remanded for a determination whether the land can be partitioned in kind without manifest injury to its value. View "Platt v. Platt" on Justia Law